This position provides leadership, direction, and oversight for the Company’s Compliance
Management System (CMS) across its indirect consumer lending operations. Works in
conjunction with the Director of Govt Affairs and senior management to set company compliance
and ethics policies, develop compliance policies & procedures with operations departments,
establish monitoring, testing, and correctional procedures, and direct the development of
communication and training on compliance and ethics. Serves as the primary compliance
contact for state regulators, examiners, and the Company’s capital markets partners.
Key Responsibilities
- Build and maintain an effective, risk-based Compliance Management System to ensure the proper systems, procedures, measurements, and quality control standards are in place for the general operation of the Compliance Department and its related activities to detect and prevent illegal, unethical, or improper conduct. Conducts an annual compliance risk assessment to prioritize monitoring, testing, and training. Consults with outside counsel as needed to resolve complex legal compliance issues.
- Directs and oversees the development of operational procedures to provide assurance that there are adequate processes and controls to meet the corporate compliance.
- Ensures that all contracts, business forms, consumer disclosures, and dealer and marketing materials comply with all applicable state and federal laws and regulations.
- Maintains state licensing for sales finance and collections where appropriate, including NMLS filings, renewals, and reporting.
- Takes lead on state exams, audits, and due diligence requests from warehouse lenders, forward-flow purchasers, and securitization counterparties, and tracks findings through remediation.
- Develop and maintain a robust complaint management process with root-cause analysis, tracking & reporting to the Board.
- Develop and maintain Policy Solutions Systems with annual policy review, employee attestation, and version control.
- Designs and executes a risk-based compliance monitoring and testing program to evaluate the implementation of compliance policies and procedures performed in all departments, and reports results to senior management.
- Lead role on third-party risk management for vendors and dealers, including onboarding due diligence, licensing verification, and ongoing monitoring, in conjunction with other Departments.
- Overseas fair lending, UDAAP, FCRA furnishing, and privacy (GLBA) compliance in coordination with Credit, Servicing, and Information Technology. With working knowledge of TILA/Reg Z, ECOA/Reg B, TCPA, FDCPA, E-SIGN, SCRA/MLA, the FTC Holder Rule, and state sales finance and licensing requirements.
- Sets standards for taking corrective action where necessary, tracks issues through remediation, and validates that corrections are implemented and effective.
- Works with the departments and support staff as appropriate to develop an effective ongoing and in-depth compliance training program, including annual role-based training and training for new employees.
- Provide compliance reporting to the Chief Executive Officer and Board on a regular basis, including key risk indicators, testing results, open issues, and Board training.
- Lead regulatory change management; stay abreast of applicable state and federal laws as they pertain to indirect consumer lending and ensure required changes are implemented.
- Performs other duties as requested.
Qualifications
Required:
- Minimum of five (5) years of direct work experience in consumer lending compliance management, including leading state regulatory examinations.
- Strong written and verbal communication skills, including presenting to senior management and the Board.
- Bachelor’s degree in related field preferred but will consider experience in lieu of education.
Preferred:
- Professional compliance certification (e.g., CRCM) and experience with GRC tools.
- Indirect or point-of-sale lending experience.